Export Realisation Is Nine Months Again: What Changed in 2026 and What Service Exporters Should Track

For exports of services invoiced on or after 1 October 2026, the full export value must be realised and repatriated within nine months from the date of the invoice. The period is twelve months where the export is invoiced or settled in Indian rupees. That is the position under Regulation 5 of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, as amended by RBI on 22 September 2026. The regulations as first notified set fifteen and eighteen months. Those figures were replaced before the regulations came into force, so they never applied.

This post sets out how the period changed over the last year, what applies now, and what a service exporter should monitor.

A year of changes, in order

There were four changes between November 2025 and September 2026, although the period actually in force changed twice: from nine to fifteen months, and back to nine.

Until November 2025: nine months. Regulation 9 of the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 required export value to be realised within nine months.
November 2025: fifteen months. Notification No. FEMA 23(R)/(7)/2025-RB, dated 13 November 2025, replaced "nine months" with "fifteen months" in Regulation 9 of the 2015 regulations.
January 2026: new regulations notified, at fifteen months. RBI notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 as Notification No. FEMA 23(R)/2026-RB, dated 13 January 2026, to take effect from 1 October 2026. As first notified, Regulation 5 set fifteen months, or eighteen months for rupee-invoiced exports.
June 2026: back to nine months under the old regulations. Notification No. FEMA 23(R)/(8)/2026-RB, dated 5 June 2026, replaced "fifteen months" with "nine months" in Regulation 9 of the 2015 regulations, from the date of its publication in the Official Gazette.
September 2026: nine months under the new regulations too. Notification No. FEMA 23(R)/(1)/2026-RB, dated 22 September 2026 and published in the Gazette on 24 September 2026, replaced "fifteen months" with "nine months" and "eighteen months" with "twelve months" in Regulation 5 of the 2026 regulations, with effect from 1 October 2026.

The fifteen-month period in the 2026 regulations therefore never came into operation. The September 2026 amendment also inserted Regulation 20, under which authorised dealer banks handle transactions from before 1 October 2026 that would earlier have needed RBI approval, and a proviso to Regulation 13 dealing with exporters on the caution list as at 30 September 2026. Neither changes the realisation period.

What applies from 1 October 2026

Under Regulation 5(1) of the 2026 regulations, as amended:

Services, including software: nine months from the date of the invoice.
Goods: nine months from the date of shipment.
Goods sent to a warehouse outside India: nine months from the date of sale from the warehouse.
Exports invoiced or settled in Indian rupees: twelve months.
Extension: the authorised dealer bank may extend the period on the exporter's request, if satisfied with the reasons given.

For a service exporter, the period runs from the invoice date, so the invoice date recorded in the books drives the deadline.

What about invoices raised before 1 October 2026?

The 2026 regulations supersede the 2015 regulations, except for things done or omitted before the supersession. Neither the June 2026 amendment nor the September 2026 amendment sets out a separate rule for exports already made when the period changed.

Practically, for any export receivable raised between November 2025 and September 2026 that is still unpaid, do not assume the longer period applies. Confirm the applicable due date with your authorised dealer bank. The bank monitors realisation and is the party that grants any extension.

How this interacts with GST

Under a Letter of Undertaking, Rule 96A(1)(b) of the CGST Rules requires an exporter of services to pay IGST with interest if payment is not received within the later of one year from the invoice date, or the period allowed under FEMA, including any RBI-permitted extension. The Commissioner may allow a further period.

With the FEMA period at nine months, the one-year limit in Rule 96A is the later date unless the FEMA period has been extended beyond one year. So two deadlines run on each unpaid export invoice:

FEMA: nine months from the invoice date, unless the bank extends it;
GST: fifteen days after the later of one year from the invoice date or the FEMA period, including any extension.

Diarise both. For foreign-currency invoices the FEMA deadline arrives first, and it is the one the bank monitors.

What happens if proceeds are not realised

The 2026 regulations give the authorised dealer several tools, and impose one significant consequence.

Extension (Regulation 5): on the exporter's request, where the bank is satisfied with the reasons given.
Reduction in realisation (Regulation 6): on the exporter's request citing the reasons for under-realisation or non-realisation, where the bank is satisfied with them. For invoices up to ₹10 lakh, or the equivalent in foreign currency, the reduction may be permitted on the exporter's declaration.
Set-off (Regulation 7): export receivables may be set off against import payables with the same overseas buyer or supplier, or its overseas group or associate companies, within the realisation period or any extended period.
Consequence (Regulation 13): where proceeds remain unrealised more than one year after the due date, including any extended date, further exports require full advance payment or an irrevocable letter of credit.

For a service exporter, this means one old unpaid invoice left unresolved can restrict the terms on which every later export is paid.

What to track, invoice by invoice

A short receivables routine covers both FEMA and GST.

Age export receivables from the invoice date and add two columns: the FEMA due date (nine months, or twelve for rupee invoices) and the GST date under Rule 96A.
Review monthly. Anything approaching its FEMA date needs either collection or a request to the bank.
Ask the bank early. Make any extension or reduction request before the due date, with the reasons and supporting correspondence.
Keep the realisation evidence, such as the bank advice, FIRC and e-BRC, against each invoice.
Close each invoice in the bank's system. From 1 October 2026, service exports are also declared through the Export Declaration Form, and the bank closes each entry once the money arrives.

Where this fits

For the evidence trail behind each receipt, see FIRC and e-BRC: the paper trail your service exports need. For the LUT and its undertaking, see Letter of Undertaking for service exporters.

Wissen Solutions tracks export receivables against FEMA and GST deadlines for service exporters, alongside GST compliance, through our GST, income tax and TDS return filing services.

Sources (checked 26 October 2026)